This paper extends the sufficient statistics approach to study international tax policy. International policy differs from domestic policies because i.) from the perspective of domestic policy makers the welfare weight on foreign agents lies below that of domestic agents, and ii.) behavioral...

Improving tax collection is essential if developing economies are to avoid over-reliance on external donor funds and loans. Revenue authorities in the Global South have recently adopted new policy tools to improve domestic revenue mobilization through taxes. One such new policy is a withholding...

Shifting intellectual property (IP) rights across jurisdictions is a well-known strategy of multinationals to reduce corporate income taxation. We investigate the extent to which the flows of remunerations for the use of IP rights are affected by differences in corporate income and withholding...

This study investigates the impact of residence country’s double tax relief method and of tax sparing agreements, on the difference between developing countries’ withholding taxes under domestic law, and negotiated withholding taxes in tax treaties with OECD member states. Using a dyadic...

This paper examines Act 32 of the Pennsylvania state legislature which mandated the introduction of withholding for the local earned income tax (EIT) for all employees and the consolidation of a fragmented collection system to one collector per county effective January 1, 2012. I find that the...

This paper examines Act 32 of the Pennsylvania state legislature which mandated the introduction of withholding for the local earned income tax (EIT) for all employees and the consolidation of a fragmented collection system to one collector per county effective January 1, 2012. I find that the...

This paper proposes a price-based measure to mitigate the destabilizing impact of the volatility of global capital movements on the domestic economy of a country pursuing sound economic policies. The measure is a withholding tax on all private capital inflows, with a credit and refund provision...

As part of Vision 2030, the Kingdom of Saudi Arabia (KSA) has begun implementing broad economic and legal reforms to improve its tax environment and create an amicable setting for international investors. However, there are challenges to this endeavour such as digitalization in income taxation...

Traditionally, international tax law has predominantly concerned itself with the avoidance of double taxation. However, the increasing influence of globalization and digitalization on domestic tax systems has made improved international cooperation inevitable. At the crux of the matter is a...

This article deals with the different concepts of non-discrimination on the basis of nationality in the OECD Model and indirect or covert discrimination in the European Treaties, as interpreted by the European Court of Justice. It discusses the different tax results of both concepts for the...

1. Introduction -- 2. Principles -- 3. Context -- 4. Variability -- 5. The Pace of Change -- 6. Tax Relief at Source -- 7. Quick Refunds -- 8. Standard Refunds -- 9. Reporting -- 10. Governance & Enforcement -- 11. United States of America -- 12. 871(m), 1446(a) and 1446(f) Withholding -- 13. EU...

This article examines the decision of the CJEU in Brisal and KBC Finance Ireland (Case C-18/15) of 13 July 2016. Following a Portuguese reference for a preliminary ruling, the Court's decision provides further clarification on the permissibility of withholding taxation within the European Union....

After 2015, it may be virtually impossible for foreign financial institutions (FFls) to avoid the reach of the Foreign Account Tax Compliance Act (FATCA),1 even if they have no United States presence nor any direct U.S. investments. This is because, beginning sometime after January 2015, FFls...

The paper analyzes the opinion of AG Hogan in the case GVC Services (C-458/18). The author argues that the Parent-Subsidiary Directive should be applicable to a parent company, incorporated in Gibraltar even if, as the case may be, this applicability derives from a teleological interpretation of...

Out of all double tax treaties (DTTs) in force in 2012, around 41% are symmetric and 59% are asymmetric, i.e., they prescribe different dividend withholding tax rates (WTRs) depending on the foreign investor's ownership fraction. The paper investigates the reasons for this phenomenon, namely why...

We examine the role of withholding taxes on foreign portfolio in-vestment (FPI) and compliance frictions in obtaining foreign tax cred-its using data on bilateral FPI around the globe and on U.S. institu-tional investor's foreign holdings. Exploiting variation in withholding tax rates for 36...

Much of the foreign direct investment worldwide is affected by one of more than 3000 bilateral tax treaties. There is an agreement that dividend and interest payments respond to these tax treaties' provisions, but evidence is scarce as to the magnitude of this response. We aim to fill in this...

The objective of this contribution is to provide the OECD with a view to designing the final 2020 Report, the EU Institutions projecting an eventual legislative action and whatever States considering or (re)considering unilateral measures in the field of taxation of the digitalized economy with...

Tax treaties between countries influence how much tax revenues governments receive from multinational enterprises. These treaties often reduce the withholding tax rates on outgoing dividend and interest payments. We provide illustrative estimates of costs for these two taxes for 14 developing...

World War II brought with it a substantial increase in federal income tax rates, and introduced income tax withholding for wage income. Rates increased prior to withholding, so an examination of tax payments paid prior to and subsequent to withholding can offer some insight into the degree to...

Traditionally, international tax law has predominantly concerned itself with the avoidance of double taxation. However, the increasing influence of globalization and digitalization on domestic tax systems has made improved international cooperation inevitable. At the crux of the matter is a...

The digital economy is characterized by the use of intellectual property such as software, patents and trademarks. The pricing of such intangibles is widely used to shift profits to low-tax countries. We analyze the role of a source tax on royalty payments for abusive transfer pricing, and...

Using a large international firm-level panel data set, we investigate the impact of corporate taxation on foreign direct investment. In this paper, we also theoretically and empirically analyse foreign corporate taxation. In particular, we examine non-resident withholding taxes. The impact of...

This position paper provides possible solutions to the challenges presented to the international tax regime by the digital economy. It considers the option of installing a broad withholding mechanism based upon the base erosion principle both as a primary response to these challenges or in...